Modern Slavery Act Statement
31 May 2018
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and relates to Capital & Regional plc and all its subsidiaries. It constitutes Capital & Regionals modern slavery and human trafficking statement for the financial year ended 30 December 2017.
Last year, Capital & Regional published its first modern slavery and human rights report. This year’s report provides an update on progress and risk assessments completed. This is Capital & Regional plc’s statement under the Modern Slavery Act 2015 (the “Act”) which applies to companies and partnerships which have a global turnover in excess of £36 million and conduct any of their business in the UK. As required by the Act, the statement reports on the steps that the Company has taken during the financial year ended 30 December 2017 to ensure that slavery and human trafficking is not taking place in any of our supply chains or in any part of our own business.
Capital & Regional is a UK focused retail property REIT specialising in community shopping centres that dominate their catchment, serving the non-discretionary and value orientated needs of their local communities. Capital & Regional is listed on the main market of the London Stock Exchange and has a secondary listing on the Johannesburg Stock Exchange.
Capital & Regional currently owns seven shopping centres in Blackburn, Hemel Hempstead, Ilford, Luton, Maidstone, Walthamstow and Wood Green. It also has a 20% joint venture interest in the Kingfisher Centre in Redditch. Capital & Regional manages these assets through its in-house expert property and asset management platform. Capital & Regional also owns Snozone, which runs the indoor ski operations at Milton Keynes and Castleford.
Across the whole business and on a full-time equivalent basis Capital & Regional employed an average of 238 people during the year ended 30 December 2017. The Group had an annual turnover of £89.2 million for the year ended 30 December 2017.
Our Approach to Human Rights
Capital & Regional supports the aims of the Act to combat slavery and human trafficking and improve the transparency of reporting on modern slavery. As part of our culture Capital & Regional operate an integral set of core values. They support the vision, shape the culture, and reflect who we are as a company. These values are reflected in our relationship with key stakeholders groups including guests, customers, suppliers and our staff. Our approach to tackling modern slavery is influenced by these business values. It forms part of our broader human rights strategy. Through which we work to raise labour standards, improve working conditions and wellbeing of our workforce. We regularly review our existing compliance and risk management processes to ensure our business and supply chain is not exposed to the threat of modern slavery or human trafficking. We expect our business partners to hold their own suppliers to the same standards in prohibiting forced, compulsory or trafficked labour.
Internal Business Assessment
Based on our internal risk assessment and standards review, we consider that the risk of any slavery or human trafficking in the employment of our employees remains low.
We have a number of policies and procedures in place that we believe promote a culture and behaviours in keeping with the Act’s objectives. These are all set out in our staff handbook and include:
- Anti-fraud, bribery and corruption policies
- Disciplinary and grievance policy
- Equal opportunities and diversity policy
- Grievance procedure
- Health and safety policy
- Whistleblowing policy
- Code of Business Conduct
- GDPR Policy
- Joint Unit Inspections Procedure (JUI’s)
In 2017 we carried out a comprehensive analysis of our standards, operations and activities to review any new emerging risks in the current reporting period. Due to the continuous fostering of our long-term relationships with our key contractor’s no further risks have been identified. The standards were reviewed as part of a planned process and not promoted by a particular event or demand from stakeholders. We use our JUI procedure to complete regular assessments of all our occupiers to ensure they are achieving the required standard of operation and provide sufficient staff welfare facilities.
Our supply chains include contractors, sub-contractors, goods and services suppliers and professional service suppliers. In most cases we aim to develop long term relationships with our key suppliers by engaging with entities that have similar cultures and values to our own. During the last 12 months we have reviewed our supply chain to identify the areas that are potentially most prone to slavery or human trafficking.
Our assessment concluded that the highest risk occurred in two areas: firstly, where we engage in large development contracts where the completion of the contract may involve the use of subcontractors, and secondly, in the outsourcing of soft services such as cleaning and security.
In the case of the former we take some, limited assurance from the size of the businesses that we engage with, which means that they will need to introduce their own procedures in order to comply with the Act. As part of the procurement process we review confirmation of compliance with the Act as part of the tendering process. During any major construction works we also complete audits of the staff welfare facilities onsite and monitor shift patterns and overnight working practises. In the case of the latter we consider the risk is mitigated by engaging with a single well-established supplier, VSG Security Group, which is part of Compass Group plc. As part of our review we considered the Modern Slavery Act statement made by Compass Group plc and were satisfied that it demonstrated an appropriate commitment on their part to ensuring compliance with the Act.
The responsibility for reviewing the Company’s ongoing compliance with the Act is undertaken by the Board’s Responsible Business Committee who report their findings to the Board.
This statement was approved by the Board on 9 May 2018.
Capital & Regional plc